Srinagar: The Group of Concerned Citizens (GCC), Jammu & Kashmir, has voiced profound apprehension regarding the recently notified amendments to the Unified Building Bye-Laws, warning that they threaten the integrity of urban planning and risk institutionalizing urban degradation across the Union Territory.
The amendments, enacted through S.O. 304 dated December 1, 2025, mandate sweeping changes to development controls—including building height, bulk, coverage, and setback norms—for all construction activities in the capital cities of Srinagar and Jammu, as well as other urban areas.
In a formal memorandum submitted to Chief Minister Omar Abdullah, the GCC has raised substantive objections, both procedural and substantive, to the new rules. The group contends that the final notification is "materially different" from the draft proposal placed for public comment in July 2024.
"The new rules have suddenly sprung up, departing from the mandatory consultative sequence required for subordinate legislation of this magnitude," the memorandum states. "They run foul of the statutory Master Plan without a formal plan amendment."
The GCC argues that the amendments effectively substitute an executive notification for established instruments of statutory planning, setting a "bad precedent that tends to weaken the integrity of rule-based urban governance." The group further identifies "serious drafting deficiencies" within S.O. 304, including the deletion of critical definitions and the creation of indeterminate setback provisions. "These ambiguities undermine uniform interpretation and enforcement, pushing both citizens and approving authorities toward avoidable litigation," the memorandum cautions.
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Questioning the core rationale behind the changes, the GCC fears they will precipitate disorderly and hazardous densification rather than planned development. The memorandum warns that diluted setbacks and increased building bulk will compromise essential requirements for light, ventilation, fire safety, and emergency access.
Furthermore, the group highlights the strain on already overburdened civic infrastructure. "These changes will place additional, untenable pressure on water supply, sewerage, drainage, and road networks," it states. "In our cities and towns, characterized by narrow streets, flood vulnerability, seismic risk, and heritage neighborhoods, such regulatory ambiguity poses direct risks to public safety, environmental health, and quality of life."
Urging the government to uphold statutory primacy and the larger public interest, the GCC has appealed for the immediate suspension of S.O. 304. It has called for a comprehensive review by a high-level committee, proposed to be headed by the Chief Secretary, with representation from relevant departments and consultation with independent experts and stakeholders.
"We hope such a review would restore procedural legitimacy, reduce legal vulnerability, and ensure any revision of building controls is aligned with statutory plans and the ecological and infrastructural capacity of our urban centers," the memorandum concludes. "The fragility of our capital cities, in particular, leaves little room for regulatory shortcuts."